Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
Index
1. - Letter from the President
2. - Introduction to the Code
3. - Enforcement and Application of the Code
4.- Commitment
A) of Grupo Antolin
B) of the employees
5. - Management of Ethics Violations
A) Whistleblowing (Grupo Ethics Link)
B) Ethics Committee
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
1.- Letter from the President
Since the beginning, Grupo Antolin has had the firm
intention of “doing what is right”. And in the world today, in
constant change, the intention to act responsibly has now
become more important than ever.
We understand Responsible Conduct is the only way to carry
out the actions and decisions of our commercial activity.
This conduct is, furthermore, independent from the location
of the activity and particularly important in developing
countries.
The values of Grupo Antolin are the foundation of our
corporate culture, and are strengthened by our creativity,
leadership, customer focused and sustainability.
Our job is to contribute to the professional and personal
growth of each and every person who is an integral part of
Grupo Antolin, through the creation of an environment of
mutual respect, free from any form of harassment or
discrimination of any kind. We want to be an innovative
company, integrated within the communities in which we
operate. And in this sentiment, the Code of Ethics and
Conduct strives to orient all employees of the company to
this way of acting.
In the corporate strategy of Grupo Antolin, we have
integrated the Ten Principles of conduct and action from the
World Pact of the United Nations on Human Rights, work,
environment and the fight against corruption.
Responsibility is the axis around which our corporate
identity revolves.
José Antolin Toledano
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
2. - Introduction to the Code
The Code of Ethics and Conduct of Grupo Antolin (hereafter
referred to as the Code) is a living document in which the
principal objective is to guarantee responsible conduct in
the development of our activities.
With this document, Grupo Antolin publicly declares its
commitment to the Universal Declaration of Human Rights,
the principles of the Global Compact of the United Nations
(of which, Grupo Antolinhas been a founding member of
since 2003), and the Organization for Economic Cooperation
and Development (OECD).
The present document reflects these values and should
serve as a guide for the conduct of the company and those
who make up the company. It should instill honesty, ethics
and professionalism in our relationships with our clients,
stockholders, employees, suppliers and with society in
general.
The Code is not a rule of internal regimen, nor is it a
substitute for the collective bargaining agreements or of the
national, international or local legislations. Nevertheless, the
company gives a prioritized level of importance to the
compliance with this Code, of which all employees of Grupo
Antolin should commit to respecting the content and spirit
of the document.
Ultimately, we should always appeal to our sense of
responsibility and good judgment, and seek counsel if ever
there is doubt regarding appropriate corporate behavior.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
3. - Enforcement and Application of the Code
This Code of Ethics and Conduct goes into effect on the
same day Grupo Antolin makes its commitment public.
This Code is subject to revisions and updates as the
Company fulfills its obligations of Corporate Responsibility,
as well as from suggestions and proposals made by the
employees and the Ethics and Conduct Committee of Grupo
Antolin.
Grupo Antolin’s commitment to this Code extends to all of
the facilities in which Grupo Antolin is a major partner or has
management control, as well as to the supply chain.
Similarly, this Code applies to all employees associated with
Grupo Antolin, independent from contracts that have been
negotiated in labor relations, the position that is held in the
organization or the territory where employed.
Anyone who violates the Code, Policies or Procedures of
Grupo Antolin is subject to disciplinary actions, up to and
including dismissal. Disciplinary actions are also applicable
to anyone who requests or approves infractions, or has any
knowledge of them but does not act immediately to seek
resolution.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
4.- Commitment
A) of Grupo Antolin
Grupo Antolin continuously strives for a sustainable future,
working to decrease the impact our activities generate on
the environment and on the people in the surrounding
communities. For this reason, we are committed to the
specific universal values that govern Grupo Antolin’s
behavior in all activities.
Human Rights:
Grupo Antolin supports the fundamentals of human rights,
and avoids and denounces participation in any commercial
activities that abuse those rights.
Labor Standards:
Grupo Antolin defends the freedom of association and
effectively acknowledges the rights of collective bargaining.
Supports the elimination of all forms of forced labor or
work which is carried out under coercion.
Respects the laws enforced in each country with regard
to work hours.
Implements policies in accordance with local
compensation laws, including minimum wage and
employment benefits.
Opposes illegal child labor practices.
Favors the elimination of discriminatory hiring and
employment practices.
And guarantees a management system with safe and
healthy work standards.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
Environment:
Grupo Antolin aspires to minimize the detrimental impact
on the environment from its commercial operations.
Fosters initiatives that promote enhanced environmental
responsibility.
And promotes the development and diffusion of processes
and technologies that are respectful of the environment.
Anti-Corruption:
Grupo Antolin is committed to supporting international and
local efforts to eliminate corruption and financial crime.
Relationships with Competitors:
Grupo Antolin is committed to competing vigorously and
competitively in the marketplace, but in full compliance with
all laws regarding competition in its different commercial
territories.
B) of the employees
• To be honest and trustworthy, basing our
competitiveness on the quality of our products and
services, avoiding situations that confuse
professional responsibilities and ethics, ensuring that
any payment, distribution or gift, for or in the name
of the company, is legal and for legitimate reasons.
• To act in an educated manner that is respectful and
fair to co-workers and professionals of Grupo
Antolin, as well as with our clients and service
providers, applying the company policies in the areas
of diversity and tolerance, without discrimination for
reasons of age, race, color, sex, language, religion,
beliefs, origin, or any other condition or circumstance,
personal and/or social.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
• To maintain the necessary level of confidentiality, within
the framework of professional ethics in all work-related
aspects of those areas, to guard all professional secrets
whenever needed, both internally and externally, with
suppliers, clients and competitors.
• To protect our own independence without letting others
influence our professional judgment, and avoid
involvement in any situation where a possible conflict of
interest or circumstance could affect our own impartial
critical judgment and objectivity.
• To achieve a healthy and secure atmosphere fulfilling
and ensuring the necessary security measures and
cleanliness, as well as making responsible use of the
resources and facilities of Grupo Antolin, when and
where work is performed, never working under the
influence of alcohol or drugs or any other illegal
substance that might cause questionable professional
behavior and/or threaten the security of others.
• To prohibit violent behavior, threats, coercion or any
form of intimidation or harassment from co-workers,
management, clients or any other agent of the company.
• To preserve company knowledge by facilitating the
dissemination of information to other Grupo employees
and willingly making available the management systems
of knowledge that enable information to be more
effectively distributed to others within the company.
• To utilize with diligence the proper technical resources
and materials provided by the Company to avoid
damage from misuse, and being responsible for the
possession, proper care of them and their use in
compliance with the rules and enforced internal
guidelines.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
• To enforce a belief in creating an agreeable and
respectful work environment, using the tools provided
for all employees by the Company to express the level of
satisfaction with the policies and processes of Grupo
Antolin.
• To contribute to the continued improvement of our
environmental behavior, integrating the environmental
policies of Grupo Antolin into our company’s conduct
and daily activities.
• To denounce any situation that violates the principles
and fundamental Rights of the people and of the
environment of each of the companies in which the
presented code applies.
• To experience the right to express our concerns and
points of view across the established inquiry channels
established to guarantee the freedom of expression.
• To represent Grupo Antolin responsibly in its
development of our professional activities, always and
everywhere, being conscious that whatever proceedings,
omissions or decisions that are made on behalf of Grupo,
directly or indirectly, affect the reputation of the
company.
• To be committed to achieving the maximum quality,
individually, as a part of a team and cooperatively,
always seeking the best continuity.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
5. Management of Ethics Violations
A) Whistleblowing (Grupo Ethics Link)
Available to all Grupo Antolin employees is the
Whistleblowing (Grupo Ethics Link) as a way to submit any
complaints and/or incident reports to be considered in a
timely manner. This communication can be made through
the Company’s Intranet, for those who have access to a
computer, and also via the following mail address:
Grupo Antolin
P.O. Box 2069
Burgos, Spain E-09007
The complaints should be identified with all of the necessary
information provided, and with the specific details of the
incident. Anonymous claims will not be accepted.
This information will be received solely by the corporate
office Human Resources Department. Periodically, the
received documentation will be presented to the Ethics
Committee. If it is determined that a complaint is valid and
can be supported, two evaluators will be designated to carry
out any interviews and to compile all of the necessary
information.
The resolution, representing the position of the company
regarding the specific conflict, will be communicated solely
to the interested parties, and will be taken under
advisement.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
It is the responsibility of each of us to apply the contents of
this Code of Ethics & Conduct in an appropriate manor, and
to in turn, help others to do the same. From here forward,
we would like to encourage everyone to express their
concerns and to inform us, in good faith and with
impartiality and respect, of any conduct or situation that is
contrary to the commitments stated in this document.
In consideration of Grupo Antolin, as a whole and in its
global position, when faced with situations concerning
corporate conduct in its International efforts, the
established policies of the company of destination and of
the origin should be available to adequately make any
decisions. If there is any doubt, however, each professional
should use their best judgment to determine the best way
to respond to the situation, seeking assistance from co-
workers, from those who are responsible, and if necessary,
from the company by submitting their concerns to the Ethics
Committee for consideration.
B) Ethics Committee
Grupo Antolin has created an Ethics Committee with the
charge to watch over the development, revision and the
fulfillment of the Code of Ethics and Conduct. And has the
authority to resolve the ethics-related conflicts that occur
within the company.
The Committee consists of a cabinet of internal
professionals, as well as of external experts in the areas of
Corporate Responsibility, labor and legal matters.
The objectives of the Ethics Committee are:
1. - To evaluate the level of symmetry between the values of
the company and the actual social and cultural environment
of the company.
2. - To develop and update the values and the present Code,
based on the internal needs of the company.
Propuesta Grupo Antolin 2010 2010
Code of Ethics & Conduct
3. - To oversee the complete adaptation to the ethics
principles and values within Grupo Antolin.
4. - To guide and support the professionals of the company.
5. - To identify, analyze and give responses to unresolved
issues.
The Ethics Committee is, furthermore, committed to
periodically providing updates on the direction of Grupo
Antolin with respect to the number and the severity of
discovered incidents, the number of interventions by the
committee and the number of corrective actions brought to
resolution, as well as an extension of knowledge of the Code
of Ethics and Conduct on behalf of the professionals of de
Grupo Antolin.
I have read, understand and am committed to
respecting the spirit and the language of the Code of
Ethics and Conduct of Grupo Antolin